On April 26, 2023, the European Commission updated Frequently Asked Questions regarding the Central Bank of Russia and, more specifically, reporting obligations introduced with the tenth package of Russia-related sanctions imposed on February 25, 2023 with the adoption of Council Regulation (EU) 2023/427. The new FAQs provide operators with access to a common template that can be used to report any immobilized assets to national competent authorities (“NCAs”) and to the Commission, in accordance with Article 5a (4) of Regulation No. 833/2014. There is also a discussion on how to determine where to send reports on immobilized assets.
On April 26, 2023, the Commission also updated the Frequently Asked Questions related to asset freezes and prohibitions on making funds and economic resources available under Council Regulation 269/2014. As part of the new sanctions imposed by the Commission on February 25, 2023, new reporting obligations were established for frozen assets belonging to designated natural and legal persons, entities and bodies in Annex I to Regulation 269/2014. The new FAQs provide an overview of the new reporting requirements for frozen assets; discussions on when the additional reporting requirements apply; and guidance to help operators determine where these reports should be sent. They also address operators’ obligation to report asset changes made two weeks prior to an individual’s or entity’s designation, with separate discussions for existing designees and for persons designated after April 26, 2023. The new FAQs also provide access to a common template used by central securities depositories (“CSDs”) to report frozen assets.